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Monday, October 23, 2017 12:01:48 AM
I’ve submitted numerous Air 106..352 PBR (“Type O”) applications to TCEQ.
They are fill-in-the-blank on forms, and fill-in-the cell on spreadsheets, or spreadsheet interface tools.
TCEQ provides the supporting tools to complete these PBR’s - they are administrative permits, and can be completed by anyone who can transcribe numbers from a spec sheet, drawing, or table, into the appropriate places on the forms, and supply the check-list elements required by the application.
For those interested, you can go here for the details:
https://www.tceq.texas.gov/permitting/air/permitbyrule/subchapter-o/oil_and_gas.html
PBR processes are intended to streamline environmental permitting. The genesis is at the federal level, via USEPA, and they are implemented at the state level, where there is a USEPA proxy, for example TCEQ in Texas.
Holding an Air 106.352 PBR issued document proves only that the applicant can fill out a form, and follow a check-list. Texas statute requires issuance of the permit if the application is complete, and correct. If you can fill out the forms, and submit the application, you’re golden, provided you can come up with the $100 fee.
I’ve read MMEX’s 153-page application, and reviewed it in detail. There is nothing special, or otherwise remarkable about it. Like hundreds of other applicants, it complies with the TCEQ PBR requirements. Big deal.
Factually, MMEX did not itself do the work - a consultancy, Trinity, prepared, and filed the application on behalf of MMEX - MMEX lacks the internal competence to have even done the trivial completion of the application using its own staff resources.
A permit issued on the basis of a PBR process is of near zero value. It represents an administrative, regulatory compliance action. MMEX is waving this in the face of unsophisticated individuals as if it carries meaning and significance. It is worth $100, and the remainder of the costs MMEX paid for preparing it and submitting it are a waste of other people’s money - the company itself lacks even the most minimal skill set to prepare and file the application.
I know that people like me are a share selling scheme like MMEX’s worst nightmare - the combination of engineering, market, finance and regulatory experience, along with decades of industry experience poke holes in their fantasy gas-bag every time they try to blow it up. MMEX is a bag of gas, the stinkiest kind. If it somehow gets off the ground, it will just auger in. Go MMEX, Go!
I’m planning on attending the groundbreaking, to photograph the team before they get free state-awarded orange jumpsuits. MMEX forever!
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